Guides/Attestation and Sustainability

SEC Climate Disclosure Rule Status: Stayed, Abandoned and Proposed for Rescission

Where the SEC's 2024 climate disclosure rules stand on November 5, 2026: the stay, the end of the SEC's defense, the Eighth Circuit abeyance, the May 29, 2026 rescission proposal and what CPA firms should tell public-company and pre-IPO clients.

CORAA TeamUpdated November 5, 20266 min read

The SEC's climate disclosure rules were adopted in March 2024 and have never taken effect. The Commission has stopped defending them and, on May 29, 2026, proposed to rescind them in their entirety. This post gives the sequence with dates, where things stand on November 5, 2026, and what it means for the work your firm does.

The timeline

Date Event
March 6, 2024 The Commission approves the climate disclosure rule amendments by a 3-2 vote
March 21, 2024 Petitions for review filed in several courts of appeals are consolidated in the Eighth Circuit
April 4, 2024 The Commission stays the rules pending completion of judicial review
March 27, 2025 The Commission votes to end its defense of the rules
September 12, 2025 The Eighth Circuit holds the petitions in abeyance until the Commission reconsiders the rules by notice-and-comment rulemaking or renews its defense
May 8, 2026 Petitioners move to lift the abeyance
May 21, 2026 The Eighth Circuit denies that motion
May 29, 2026 The Commission proposes to rescind the rules (Release No. 33-11421)
June 1, 2026 The SEC files a letter with the Eighth Circuit about the issuance of the proposed rule

The SEC's materials and the Iowa v. SEC docket (Eighth Circuit) support these entries. The SEC's own materials describe a proposal, not a final rule, and no final rescission has been announced.

What the rules would have required

The Commission's fact sheet describes the 2024 amendments as mandating highly specific and granular disclosure about climate-related matters, such as greenhouse gas emissions, the management of climate-related risks and the financial statement effects of severe weather events, applicable to virtually all public companies. The proposing release describes them as requirements for registration statements and annual reports.

None of that is in force. A company filing a 10-K for fiscal 2026 has no obligation under these rules.

The proposed rescission

The Commission's press release (2026-49) and fact sheet say it proposes to rescind the climate disclosure rules in their entirety. The stated grounds are:

  • The rules exceed the statutory limits on the Commission's disclosure authority.
  • Independently, they are unnecessary and inconsistent with a registrant-specific, materiality-based approach to disclosure.
  • They stray beyond the policy concerns of the federal securities laws.
  • They impose costs that are not justified by the informational benefits they may provide to some investors.
  • They conflict with the objectives of facilitating capital formation and promoting public company status.

Chairman Paul Atkins said disclosure obligations should be guided by "materiality as the North Star." The proposing release was published in the Federal Register on June 3, 2026, and comments were due by August 3, 2026. A final rule needs a further Commission vote. Until then, the rules remain stayed and the Eighth Circuit petitions remain in abeyance.

What stays the same

The rescission proposal does not change the general standard. Disclosure that is material to an investor's decision remains the test, which is the framing the Commission itself uses. A climate event that materially affects a registrant's results, such as a hurricane loss, a wildfire impairment or a regulatory cost, is still a matter for the financial statements and for MD&A under existing requirements. See MD&A guide and Form 10-K disclosure checklist.

Clients also keep other reasons to report climate information. California's laws apply to large companies regardless of SEC registration. Covered entities that face them should read California SB 253 and SB 261. Companies with EU operations may be covered by the EU directive discussed in CSRD and US companies. Lenders and customers continue to ask for emissions data on a voluntary basis, which is an attest engagement covered in ESG assurance for CPAs.

What to tell clients

  1. Public companies. Do not plan the 2026 filing around the 2024 rules. Confirm that existing climate-related statements in the 10-K, the sustainability report and investor materials are consistent with each other and supported.
  2. Companies planning an IPO. The same applies. The 2024 rules would have applied to registration statements, and they are stayed there too.
  3. Clients that began building emissions inventories for the SEC rule. The data work still serves California reporting, EU requests and lender questionnaires. Keep it, but scope it to the regime that applies.
  4. Your own engagements. Any assurance on voluntary sustainability information is an attest engagement with its own criteria and independence requirements, not a requirement of the audit of financial statements.

What to watch

  • A final rescission release from the Commission, and its effective date.
  • Any further order from the Eighth Circuit. The abeyance continues until the Commission completes reconsideration or renews its defense.

FAQ

Are the SEC climate rules in effect?

No. The Commission stayed them on April 4, 2024 and has never lifted the stay.

Why did the Commission propose to rescind them?

The proposing release says the rules exceed the Commission's statutory authority and, independently, are unsound policy.

Does the rescission proposal affect California or EU requirements?

No. Those regimes rest on separate laws and apply on their own terms.

Sources

CORAA prepares ready-to-review audit files for US CPA firms from QuickBooks books; you review and sign. See /us.

Part of CORAA University · SEC reporting and PCAOB audits: related guides, calculators and templates.

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AU-C references are to AICPA Professional Standards, paraphrased here; read the standard itself before relying on a requirement. This page is guidance, not professional advice. Report an error

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